Key Takeaways Definition of “social media intermediaries” too broad. Exceptions for some use cases would have made great sense. Need clarity on the 5 million threshold. How do significant social media intermediaries define “5 million users” — daily or monthly active users, or registered users and so on? 5 million number is very low in India Need consultations for an “intelligent definition” for intermediaries Personal liability of chief compliance officer a might be too much risk for one person Timelines for grievance redressal might be too onerous on companies Rules might achieve opposite of curtailing platform power Compliance burden on smaller platforms high The Information Technology (Guidelines For Intermediaries And Digital Media Ethics Code) Rules, 2021 notified earlier this year change the way the internet is governed in India. The Rules prescribe several new and onerous requirements for companies. For the first time ever, social media intermediaries have been carved out as a separate category. Large social media intermediaries have been prescribed additional responsibilities which could significantly impact their business operations in the country.